EU AI ActNIST AI Risk Management Framework (AI RMF 1.0)

EU AI Act covers 66.7% of NIST AI Risk Management Framework (AI RMF 1.0)

48 of the 72 controls in NIST AI Risk Management Framework (AI RMF 1.0) are already satisfied by evidence you collected for EU AI Act. 24 are genuine gaps. Every claim below was judged against both control sets and then argued against; the ones that did not survive are published further down with the reason each failed.

66.7%
of the target already covered
48
controls evidenced
24
genuine gaps
10
claims rejected in review

What this leaves you to do

NIST AI Risk Management Framework (AI RMF 1.0) has 72 controls. Holding EU AI Act already evidences 48 of them, so the work in front of you is 24 controls, not 72, which is 33% of the standard rather than all of it.

That is the whole claim. We do not know your hourly rate, how long a control takes you, or how many people you have, so there is no figure here in dollars or weeks. Every number in that sentence comes from the two counts above it and can be re-derived from the free tools without taking our word for any of it.

This number is directional. It says how much of NIST AI Risk Management Framework (AI RMF 1.0) your EU AI Act evidence satisfies. The reverse pair is a different number, often very different, because a security standard has enormous depth for access control and almost none for lawful basis or data subject rights.

72 candidate mappings were examined and 10 were removed. Signed off 2026-08-20, review level machine verified. Mappings were judged by Claude Code rather than read line by line by a practitioner. Every claim shows its reasoning so you can check it. Ask and a practitioner will review this pair.

Where the gaps are

Coverage is never evenly spread. A source standard usually satisfies one part of a target almost completely and barely touches another, and which part is which is the thing worth knowing before you plan the work.

MEASURE - NIST AI RMF 1.016 of 22 evidenced, 6 to do
MAP - NIST AI RMF 1.013 of 18 evidenced, 5 to do
MANAGE - NIST AI RMF 1.08 of 13 evidenced, 5 to do
GOVERN - NIST AI RMF 1.011 of 19 evidenced, 8 to do

Theme level, not control level, deliberately. The per-control list of what is evidenced and what is a gap is the report itself, so publishing it here would be publishing the thing being sold.

Claims that held

A sample. Each one names the control whose evidence does the work, the control it satisfies, and why.

EUAI-Art.6AIRMF-GV-1.1argued against and upheld
Legal and regulatory requirements involving AI are understood, managed, and documented

The recorded high-risk determination per system is documented understanding of which legal regime binds it.

EUAI-Art.17AIRMF-GV-1.2argued against and upheld
The characteristics of trustworthy AI are integrated into organizational policies, processes, and procedures

A written QMS carrying compliance strategy, design control, data management and accountability integrates these characteristics into procedure.

EUAI-Art.6AIRMF-GV-1.3argued against and upheld
Processes and procedures are in place to determine the needed level of risk management activities based on the organization's risk tolerance

Classification determines which obligation set applies, which is the same tiering-drives-effort mechanism.

EUAI-Art.9AIRMF-GV-1.4argued against and upheld
The risk management process and its outcomes are established through transparent policies, procedures, and other controls based on organizational risk priorities

A documented, maintained, continuously iterative risk management system is this process and its outcomes.

EUAI-Art.49AIRMF-GV-1.6argued against and upheld
Mechanisms are in place to inventory AI systems and are resourced according to organizational risk priorities

Registering each system in the EU database before market placement is a maintained AI system inventory.

EUAI-Art.17AIRMF-GV-2.1argued against and upheld
Roles and responsibilities and lines of communication related to mapping, measuring, and managing AI risks are documented and are clear to individuals and teams throughout the organization

The QMS accountability framework sets out management and staff responsibilities across the lifecycle.

EUAI-Art.4AIRMF-GV-2.2argued against and upheld
The organization's personnel and partners receive AI risk management training to enable them to perform their duties and responsibilities consistent with related policies, procedures, and agreements

AI literacy calibrated to knowledge, context and affected persons, for staff and those acting on their behalf.

EUAI-Art.14AIRMF-GV-3.2argued against and upheld
Policies and procedures are in place to define and differentiate roles and responsibilities for human-AI configurations and oversight of AI systems

Article 14 specifies what the overseeing person must be enabled to do, which differentiates the human-AI roles.

Claims that did not hold

10 proposed mappings for this pair were rejected. They are kept in the graph rather than deleted, so what was thrown out is as inspectable as what survived. A crosswalk that never rejects anything is not being judged.

EUAI-Art.16-22AIRMF-GV-2.1
Roles and responsibilities and lines of communication related to mapping, measuring, and managing AI risks are documented and are clear to individuals and teams throughout the organization

Judged against a node bundling seven distinct provider obligations. The recorded intent says only provider obligations against roles and responsibilities, which sits equally on Art.16, the list of provider duties, and on Art.17(1)(m), the accountability framework inside the quality management system. Two candidate articles is not an unambiguous re-home.

Claimed at refuted confidence before it was rejected.

EUAI-Art.14AIRMF-GV-1.2
The characteristics of trustworthy AI are integrated into organizational policies, processes, and procedures

Refuted in review.

EUAI-Art.55AIRMF-MN-1.1
A determination is made as to whether the AI system achieves its intended purpose and stated objectives and whether its development or deployment should proceed

Refuted in review.

EUAI-Art.9AIRMF-MN-1.1
A determination is made as to whether the AI system achieves its intended purpose and stated objectives and whether its development or deployment should proceed

Refuted in review.

EUAI-Art.72AIRMF-MN-2.1
Resources required to manage AI risks are taken into account, along with viable non-AI alternative systems, approaches, or methods, to reduce the magnitude or likelihood of potential impacts

Refuted in review.

Claimed at unrated confidence before it was rejected.

EUAI-Art.9AIRMF-MN-2.1
Resources required to manage AI risks are taken into account, along with viable non-AI alternative systems, approaches, or methods, to reduce the magnitude or likelihood of potential impacts

Refuted in review.

EUAI-Art.11AIRMF-MN-4.1
Post-deployment AI system monitoring plans are implemented, including mechanisms for capturing and evaluating input from users and other relevant AI actors, appeal and override, decommissioning, incident response, recovery, and change management

Refuted in review.

EUAI-Art.10AIRMF-MP-1.1
Intended purpose, potentially beneficial uses, context-specific laws, norms and expectations, and prospective settings in which the AI system will be deployed are understood and documented

Refuted in review.

The full report

Everything above is a sample. The report is every evidenced control and every gap, with the reasoning and the source document behind each one, in a form you can hand to an assessor. $299, emailed immediately.

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